THOMAS A. JOHNSON, #119203, Attorney for Nadeem Khan
STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
The United States of America through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with Thomas A. Johnson, counsel for defendant Nadeem Khan, Michael Petrik, Jr., counsel for defendant Robb Cheal, Olaf Hedberg, counsel for defendant Robert Carrillo, and Christopher Cosca, counsel for defendant Ryan Cheal, hereby stipulate the following:
1. By previous order, this matter was set for status conference on June 6, 2013.
2. By this stipulation, defendants now move to continue the status conference to September 5, 2013, at 9:30 a.m., and to exclude time between June 6, 2013, and September 5, 2013 under the Local Code T-4 (to allow defense counsel time to prepare).
3. The parties agree and stipulate, and request the Court find the following:
a. Defense counsel for Robert Carrillo, Olaf Hedberg, is currently in a trial.
b. Additionally, a continuance is requested because all counsel for the defendants need additional time to review the discovery, conduct investigation, and discuss potential resolutions.
c. Counsel for defendants believe the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
d. The Government does not object to the continuance.
e. Based on the above-stated findings, the ends of justice served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial within the original date prescribed by the Speedy Trial Act.
f. For the purpose of computing time under the Speedy Trial Act, 18 United States Code Section 3161(h)(7)(A) within which trial must commence, the time period of June 6, 2013, to September 5, 2013, inclusive, is deemed excludable pursuant to 18 United States Code Section 3161(h)(7)(A) and (B)(iv), corresponding to Local Code T-4 because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from ...